in Re H.F., 02-16-00347-CV

Title IV‑D associate judge signed a proposed SAPCR order on June 20, 2016; Father filed a notice of appeal (requesting de novo review) on June 23, 2016 that did not specify issues.
Grandmother filed a petition in intervention on June 23, 2016 seeking leave to intervene under Tex. Fam. Code §102.004(b).
Mother moved to strike Grandmother’s intervention and to dismiss Father’s appeal; the district court held a hearing August 15, 2016 and orally denied the motion and granted Grandmother leave to intervene.
The district court signed a written order on August 30, 2016 memorializing denial of Mother’s motion to strike (but not expressly the grant of leave).
The court of appeals concluded Father’s June 23 notice for de novo review was legally insufficient, so the associate judge’s proposed order became the court’s final order by operation of law on June 23, 2016, and the SAPCR ceased to be pending that day.
Because no timely postjudgment motion was filed, the trial court’s plenary power expired within 30 days after June 23, 2016; the court’s August 30, 2016 order denying the motion to strike was therefore entered after plenary power expired and was void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Father’s notice entitled him to a de novo hearing	Father’s notice constituted an appeal request	Mother/Grandmother: notice failed to specify issues as required	Notice deficient; no entitlement to de novo hearing
Whether the associate judge’s proposed order became final	Mother: became final by operation of law due to deficient notice	Grandmother: SAPCR still pending; court could allow intervention	It became final on June 23, 2016 by operation of law
Whether Grandmother could intervene after June 23, 2016	Mother: intervention requires leave while SAPCR pending; none granted before finality	Grandmother: filed petition June 23 and later was granted leave	Grandmother was not a party before finality and could not be granted leave after plenary expired
Whether the trial court’s post‑plenary order denying motion to strike is void and mandamus is appropriate	Mother: order entered after plenary power expired is void; seek mandamus	Grandmother: (declined to oppose mandamus)	Order void; mandamus conditionally granted to vacate the order

In re State, 355 S.W.3d 611 (Tex. 2011) (mandamus proper to correct clear abuse when no adequate appellate remedy)
In re Sw. Bell Tel. Co., 35 S.W.3d 602 (Tex. 2000) (orders entered after plenary power expires are void; mandamus appropriate)
Lehmann v. Har‑Con Corp., 39 S.W.3d 191 (Tex. 2001) (final order disposes of all parties and claims)
In re E.M., 54 S.W.3d 849 (Tex. App.—Corpus Christi 2001) (timely de novo request must specify issues; otherwise no de novo hearing)
Jasek v. Tex. Dep’t of Family & Protective Servs., 348 S.W.3d 523 (Tex. App.—Austin 2011) (a final SAPCR order ends the pending proceeding)
Malone v. Hampton, 182 S.W.3d 465 (Tex. App.—Dallas 2006) (judicial action taken after court loses jurisdiction is a nullity)